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Full text of "North Shore Railway, further statement of facts, with a supplement"

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3 9004 01515875 8 



NORTH SHORE RAILWAY, 



FURTHER STATEMENT OF FACTS. 

WITH A SUPPLEMENT. 



By SILAS SEYMOUR, 

Genkral Consulting Engineer. 



QUEBEC, FEBRUARY 17th & 20th 1877. 






V 



I'XoliLl 



NORTH SHORE RAILWAY, 



FURTHER STATEMENT OF FACTS, 

IN RELATION TO CERTAIN 

MATTERS IN DIFFERENCE 

Between THOMAS McGREEVY, Contractor, 

AND 

SILAS SEYMOUR, General Consulting Engineer. 



WITH A SUPPLEMENT 



" The cry is, still they come 11 " 

Macbeth. 



QUEBEC. FEBRUARY 17th & 20th 1877. 



Digitized by the Internet Archive 
in 2013 



http://archive.org/details/northshorerailwaOOseym 



NORTH SHORE RAILWAY 



FURTHER STATEMENT OF FACTS 



In relation to matters in difference betwee?i Silas 
Seymour, General Consulting Engineer, and Thomas 
McGreevy, Contractor for the North Shore Railway. 



On the 10th of May, 1876, I published, in pamphlet 
form, a " Statement of Facts, " in relation to certain " Special 
Agreements, ' ; between Mr. McGreevy and myself, which 
had been entered into during the summer of 1875. 

The first of these .Agreements, dated June 21st, 1875, 
had reference to my obtaining outside parties, who would 
either furnish Mr. McGreevy with the necessary capital to 
enable him to carry out, successfully, his original Contract 
with the North Shore, Railway Company, for the construc- 
tion and equipment of the Road ; or take the Contract 
entirely off his hands, and repay him the amount of his 
advances. 



4 FURTHER STATEMENT OF FACTS. 

The second of these Agreements, dated August 1 8th 
1875, and after the Railway Company had virtually 
abandoned the Road, had reference to the negotiations 
then being carried on, between Mr. McG-reevy and the 
Provincial Government of Quebec, respecting an entirely 
new Contract for the construction of the Road. 

The " Statement of Facts, " above referred to, was not 
printed until after I had spent several months, in the vain 
endeavor to obtain a settlement with Air. McG-reevy, for 
the extra services which I had performed in his behalf, 
under these Special Agreements ; and until after it had 
become clearly evident that he intended to repudiate his 
engagements ; and force me either to abandon my claims* 
or to resort to such legal remedies as might remain open 
to me. 

My object in printing such a statement at the time, is 
fully set forth in the following extract from the " Expla- 
natory " remarks, at the commencement of the pamphlet. 

" The following " Statement of Facts " in relation # to the 
several matters therein referred to, has been compiled with 
much care, from originals and copies of letters, documents, 
and other memoranda in my possession ; and printed for 
the exclusive use and convenience of myself and my 
Agents or Attorneys, in the prosecution or disposal of my 
claims against the Honorable Thomas McGreevy, M. P., 
and Contractor for the North Shore Railway." 

" No general circulation will be given to the document, 
by myself at least, either at present, Qr hereafter, unless it 
shall be found necessary to do so for the purpose of 
vindicating my own private character and professional 
reputation, against malicious attacks which may be ma.r^ 



FURTHER STATEMENT OF FACTS. 5 

upon them by interested parties, in advance of a full 
development of all the facts in the case, before a Court of 
Justice." 

I will now state, with equal frankness, that the present 
11 Further Statement of Facts" is published for the purpose 
of showing that Mr. McGreevy, in his efforts to free him- 
self from his legal, as well as Honorable engagements with 
me, has made the most malicious and unwarrantable 
attacks upon my private character and professional repu- 
tation ; and, also, that the fact of his having done this, 
affords me, in my own opinion, at least, the fullest justifi- 
cation for giving general publicity, not only to the " State m 
ment of Facts " above referred to ; but to the base and 
disreputable means which have thus far been resorted to, 
by himself and his Attorneys, in their attempts to under- 
mine and destroy my own character and reputation, for 
the purpose of shielding him from his just and legal obli- 
gations.* 

For my rjresent purpose, it will be sufficient to refer to 
the " Legal Proceedings, " (which I have also published in 
pamphlet form) based upon the Agreement dated August 
18th, 1875, of which the following is a true copy, as 
acknowledged by Mr. McGreevy himself, in his testimony 
in the case. 

" Quebec, August 18th, 1875." 
" Dear Sir, 

In consideration for your extra services, I 
hereby agree, that if I close an arrangement with the 
Provincial Government of Quebec, by which the Govern- 
ment either takes the North Shore Eailway Contract off 
my hands, or pays me a cash consideration for performing 



6 FURTHER STATEMENT OF FACTS. 

the Contract, I will pay you five thousand, dollars upon 
the closing of such an arrangement; also five thousand 
dollars additional, within one year from that date ; —and 
five thousand dollars additional, within two years from 
that date ; — making in all, fifteen thousand dollars. 

Yours truly, 
(Signed,) THOMAS McGREEVY. 
General Silas Seymour, 
Consulting Engineer, &c, 

Quebec." 

A reference to these Legal proceedings will show, that 
my Declaration was dated June 9th 1876, or nearly six 
months after the first instalment of $5,000 had become 
due under the above Agreement ; and that the suit was 
brought for the recovery of this amount, with interest* 
and costs. 

It will also be seen, that the Defendant's Answer* dated 
July 6th, 1876, contains, substantially, the following allega- 
tions : 

1st. That inasmuch as I was the salaried Officer of the 
North Shore Railway Company at the time, any matter or 
thing done or performed by me, in connection with said 
Railway, was so done and performed, in behalf of the 
Railway Company, and not for the Defendant. 

2nd. That my continuing to hold office under said Com- 
pany, disqualified me from rendering any service to the 
Defendant, in connection with said Railway. 

3rd. That I acted adversely to the Defendant's interests, 
and purposely injured him, both by words and deeds, in 
connection with these negotiations with the Government ; 



FURTHER STATEMENT OF FACTS. 7 

and the subsequent ratification of the Contract, by the 
Provincial Legislature. 

4th. That I never performed any of the services con- 
templated, or alluded to in the Agreement of August 18th' 
1S75 ; or was willing to perform the same, or any of 
them. 

5th. That by deceitfully pretending that I had performed 
such services ; and concealing from him the fact 4hat I 
had acted adversely to the Defendant's interests, I obtained 
from him certain payments, to which I ivas not entitled, 
and did not earn. 

It will be soen from the above, that I am charged by 
Mr. McG-reevy with conduct unbecoming to my profession 
and official position ; also with double dealing, deceit, pre- 
tense, concealment ; and with obtaining money under false 
pretenses ; all of which charges and allegations, are to day 
and have for several months past, been spread out upon 
the pubMc records of the Court, over the signature of his 
Attorneys, Messrs Andrews, Caron and Andrews. 

I will not pause, at the present moment, to make any 
comment upon either the principles, or the animus, which 
must have predominated in the mind which dictated 
these charges and allegations ; particularly when it was 
fully known at the time, that every one of them was 
false ; and, as the event proved, not a particle of evidence 
was offered in the case, to sustain them ; or to remark upon 
the damaging effect which such false and malicious charges 
must necessarily have upon my own private character, and 
professional reputation. 

It is proposed, however, to give, in this place, and as a 
matter for future, and most important reference, an extract 



8 FURTHER STATEMENT OF FACTS. 

from Mr. McGreevy's own testimony in the case, for the 
purpose of showing the reasons, which at that particular 
time, he thought proper to give, under oath, to the Court, 
for having signed the Agreement of August 18th, 1875 ; 
and also the nature and extent of the extra services referred 
to therein, which, at that time, and from his own point of 
view, I was expected to perform, under that Agreement. 



Extract from the Testimony of Hon. Thomas McGreevy, 
given at Enqaete, Oct. 12th, 1876. 



" In August and September 1875, I had occasion to have 
several interviews w 7 ith the Plaintiff, with reference to the 
proposed arrangement about to be entered into *for the 
construction of the North Shore Railway by the Govern- 
ment; and during this time there were frequent negotia- 
tions carried on between me and the Government, to come 
to an understanding in the matter. 

" One of the principal objects w r as, that the Government 
should undertake the construction of the Road, instead of 
the Rail w r ay Company ; and another principal object w^as, 
to substitute a cash basis for payments, in lieu of Railway 
Bonds, and subsidies. It is not true that I, on occasions, 
sought the assistance of the Plaintiff ; but he sent for me, 
and told me that the Treasurer of the Province had called 
on him to assist him in preparing the draft of Contract, 
Schedules, and Estimates. 



FURTHER STATEMENT OF FACTS. 9 

" I was very desirous that the thing should be put 
through as soon as possible ; and that there should be no 
delay. / signed an Agreement, during these interviews, with 
the Plaintiff, upon which this action is based, in order that 
there should be no delays, as before stated ; knowing that the 
Plaintiff had the means in his power of keeping it back ; 
which I would not have done under any other circumstances. 
It was not signed for services rendered, and only for the 
reason above mentioned." 



The following is a copy of the judgment rendered in 
th£ above mentioned case, on the 7th of February, 1877 : 

Copy of Judgment, in Superior Court, for the first 
instalment, under Agreement of August l&th 1875. 



" Considering that the Defendant hath failed to prove the 
allegations of his plea of Perpetual Exception, in this cause 
lyled, the same is hence dismissed. 

" Considering that the Plaintiffhath proved the material 
allegations of his Declaration ; and more particularly, that 
the Defendant, if he closed an Agreement with the Pro- 
vincial Government of Quebec, by which the Government 
either took the North Shore Eailway Contract oil' his hands • 
or paid him a cash consideration for performing the 
Contract ; in consideration of the Plaintiff's Extra Services, 
agreed to pay the Plaintiff five thousand dollars upon the 
closing of such an arrangement ; also five thousand dollars 
additional, within one year from that date ; and five 
thousand dollars additional, within two years from that 
date ; making in all fifteen thousand dollars : 



10 FUETIIEK STATEMENT CF FACTS. 

" Considering- that the Defendant has closed an arrange- 
ment with the said Gov eminent, by which it pays the 
Defendant a cash consideration for performing the North 
Shore Railway Contract : 

" The Court doth adjudge and condemn the Defendant, 
for the considerations aforesaid, to pay to the Plaintiff the 
sum of Five thousand dollars, with interest and costs. " 



Referring the reader to the Pamphlet, hereinbefore men- 
tioned, for any farther particulars respecting my first suit 
against Mr. McGreevy, under his Agreement of August 
18th, 1875, I will now proceed to notice the Legal Pro- 
ceedings, so far as they have progressed, under the second 
suit, which has been instituted for the recovery of the 
second instalment of $5,000 which became due, under the 
same Agreement, on the 24th of December, 3S76. Or 
within one year from the date of the closing of the arrange- 
ment, with the Provincial Government, therein referred 
to. 

The Plaintiffs Declaration is this case is dated, Quebec 
January 15th, 1877, or some twenty days prior to the ren- 
dering, by the Court, of Judgment in the first case. 

The Defendant's Answer is dated on the 8th of February 
1877, or one day after the rendering of Judgment in the first 
case. 

In order to a perfect understanding of the matter, the 
full text of each of these documents will be given, as 
follows : 



PLAINTIFF'S DECLARATION 



Silas Seymour, of the city of Quebec, in the district of 
Quebec, Civil Engineer, complaining of the Honorable 
Thomas McG-reevy, of the same place, Railroad Contractor, 
by this, his Declaration represents : 

That the Plaintiff is, and has been for many years, a 
General Consulting Engineer, acting as such, more espe- 
cially, in so far as relates to the construction and equipment 
of Railways, at Quebec and elsewhere. 

That the Defendant was, from the 21st of February, 
1874, to the 24th of September, 1875, the Contractor for the 
construction of the North Shore Railway, then being built 
and constructed by the North Shore Railway Company, a 
body politic and corporate. 

That in the month of August, 1875, the Defendant entered 
into negotiations with the Government of the Province of 
Quebec, with a view of obtaining from the said Govern_ 
ment, the Contract for the building of the said North Shore 
Railway, on the basis of a cash consideration ; or of being- 
relieved from the Contract already entered into for the 
construction of the said Railway, which it was then 
expected would be taken in hand, and built by the said 
Government. 



12 FURTHER STATEMENT OF FACTS. 

That, during the said negotiations, the said Defendant 
applied to the Plaintiff, as General Consulting Engineer, 
as aforesaid, for his aid and assistance therein. 

That, on the 24th of September, 1875, the said negotia- 
tions ended ; and a Contract was entered into, between 
the Government of the Province of Quebec, and the Defen- 
dant, for the construction of the said North Shore Railway, 
for a cash consideration to be paid the Defendant for 
performing the Contract therein mentioned ; which Contract 
was subsequently ratified and approved by the Legislature 
of the Province of Quebec, on the 24th December, 1875 ; 
and the said Grovernment authorized to carry out the 
same ; and to build and construct the said Road. 

That, during all the said negotiations, the said Defendant 
had the aid, assistance, counsel, and advice of the Plaintiff, 
as General Consulting Engineer, as aforesaid ; and that 
the Plaintiff rendered the Defendant many and important 
services in connection therewith ; all which enured to his 
profit and advantage. 

That in consideration thereof, the said Defendant, by 
paper writing, bearing date at Quebec, the 18th of August 
1875, promised and bound himself towards the Plaintiff, 
as follows : 

" In consideration for your extra services," (to wit, those 
above mentioned) " I hereby agree, that, if I close an 
" arrangement with the Provincial Government of Quebec, 
" by which the Government either takes the North 
" Shore Railway Contract off my hands ; or pays me a 
" cash consideration for performing the Contract, I will 
" pay you five thousand dollars, upon the closing of such 
" an arrangement ; also five thousand dollars additional, 



plaintiff's declaration 13 

** within one year from that date ; and five thousand 
u dollars additional, within two years from that date ; 
" making in all, fifteen thousand dollars. " 

That, in view of the premises, there is due by the 
Defendant, to the Plaintiff, the sum of five thousand 
dollars ; being the second instalment due under the afore- 
said Agreement, or paper writing, and therein mentioned 
as the sum of five thousand dollars additional, payable 
within one year from the aforesaid date, of the 24th De- 
cember, 1875 ; and which said sum, or second instalment 
became due and payable, by the Defendant to the Plaintiff* 
on the 24th day of December last ; and which said sum the 
Defendant refuses and neglects to pay, though often there- 
unto requested. 

Wherefore, the Plaintiff prays that, by the Judgment of 
this Honorable Court, the Defendant be condemned to pay 
to him the said sum of five thousand dollars, with interest 
and costs, distracted in favor of the undersigned. 

(Signed), ALLEYN & CHAUVEAU, 

Attorneys for Plaintiff 
Quebec, January 15th, 1875, 



DEFENDANTS ANSWER. 



And the said Defendant, for answer unto the Demande 
of him the said Plaintiff, in the Declaration of him the said 
Plaintiff in this cause fyled contained, not confessing or 
acknowledging any of the matters or things in the said 
Declaration set forth alleged to be true, by this his Perpe- 
tual Exception Peremptoire en Droit, saith, that the Plaintiff 
by Law, cannot at any time have or maintain any action 
against the said Defendant, for or by reason of the matters 
and things in the said Declaration set forth and alleged, or 
of any or either of them, because he says : 

That during all the times in which the Plaintiff, in his 
said Declaration alleges that he performed services for the 
Defendant, he the Plaintiff was a paid officer of the North 
Shore Railway Company, receiving as such officer a large 
annual salary ; ' and any lawful matter by the Plaintiff, 
during the said periods, in relation to or connected with 
the said North Shore Railway, or its construction ; or in 
relation to the contract for the construction thereof, done 
by the Plaintiff, was so done as such paid officer of the 
said Company ; and for the said Company, and not for him 
the said Defendant, or in his, the said Denfendant's interest. 

That the holding, by the Plaintiff, of the said office, 



defendant's answer. 15 

disqualified him from legally rendering the said Defendant 
any services in connection with the said Railroad, its con- 
struction, or the contract for its construction ; and in fact 
the said Plaintiff did not render the said Defendant any 
services, or in any manner advance the interest of the 
Defendant in the premises; but on the contrary, acted 
adversely ; and opposed his wishes and desires, in reference 
to the matters in relation to the Defendant's Contract for 
the construction of the said Road, and the ratification by 
the Legislature of this Province, of the Contract between 
the said Defendant and the said Government. 

Wherefore the said Defendant prays the dismissal of the 
Plaintiff's action in this behalf, with costs. 

And the said Defendant, for further plea to the said 
Declaration, saith, that he the said Plaintiff, deceitfully 
pretending that he had rendered him, the Defendant, 
assistance and services, which in facthe had not, and could, 
not lawfully render, obtained from the Defendant a sum 
of two hundred dollars, paid by him, the Defendant 
to J. Gr. Colston, Esquire, Advocate, at the request, and 
upon the written order of him, the said Plaintiff; and 
also obtained from him, the Defendant, two negotiable 
pormissory notes, dated at Quebec the first of May, 
eighteen hundred and seventy-six, for the sum of twelve 
hundred dollars each, payable, respectively, three and four 
months after their said dates ; and which said notes, he the 
said Plaintiff, has negotiated, and received the proceeds 
thereof; and never gave any legal consideration for the 
same. 

And the Defendant avers, that the said notes, and 
the said moneys were exacted and given ; and the 



16 FURTHER STATEMENT OF FACTS. 

letter by the said Defendant signed, dated at Quebec, the 
eighteenth day of August in the year one thousand eight 
hundred and seventy five, upon which the Plaintiffs 
action is founded, and declared upon in his Declaration, 
were solicited by the said Plaintiff, and written and con- 
sented by the Defendant, and by the Plaintiff received, as 
a bribe ; and with the corrupt intention that he, the 
Plaintiff, should fail in his duty, as such officer of the said 
North Shore Eailway Company, in its relations with the 
said Defendant ; and not exact from the said Defendant a 
strict and faithful performance of the said Defendant's 
contract, as Contractor for the said Eoad. 

And the Defendant further alleges, that the Plaintiff did 
corruptly obtain from him, the Defendant, the said 
writings and promises, with the distinct understanding 
between them, that he, the Defendant, would be aided by 
him, the Plaintiff, in evading an honest and faithful exe" 
cution of his said contract for the said Eailway. And the 
said Defendant, yielding to the suggestions of the said 
Plaintiff, agreed with him to make him the said several 
promises. And he, the said Plaintiff, with the corrupt 
view of receiving the amount of the said sums so pro- 
mised, undertook to aid and assist him, the Defendant, in 
evading a faithful execution of his, the Defendant's con- 
tract for the construction of the said Eoad. 

And so the Defendant saith, that all the understandings 
and promises mentioned in the said Plaintiff's Declaration' 
were without legal consideration, and were corruptly and 
immorally solicited, exacted, stipulated for, and received 
by him, the Plaintiff, as a bribe; and were so by the 
Defendant made and given, upon the understanding that 



DEFENDANT S ANSWER. 17 

he, the Plaintiff, would assist the Defendant, in an unfaith. 
ful and imperfect execution of his agreement as Contractor 
for the said Railroad ; and are therefore illegal, null, and 
void. 

All which allegations, the said Defendant doth hereby 
aver to be true, and well founded in fact and in law ; and 
the same will verify, prove and maintain, when and as 
this Honorable Court shall direct. 

Wherefore the said Defendant humbly prays that, for 
the causes aforesaid, by the Judgment of this Honorable 
Court, the action of the said Plaintiff in his behalf, be 
hence dismissed with costs ; of which costs, the under- 
signed Attorneys, pray distraction in their favor. 

Quebec, 8th February, 1877. 

(Signed,) ANDREWS, CARON & ANDREWS, 

Attys. for Defendant, 



18 



FURTHER STATEMENT OF FACTS. 



In connection with the latter part of the foregoing 
" Answer " by the Defendant, I desire the reader to refer 
immediately back to the testimony given under the solem- 
nity of an Oath, in relation to the same matter, and by the 
same Defendant, on the 12th October, 1876. 

In order to bring these remarkable documents face to face 
with each other, it will be better, perhaps, to print the 
following extracts from each, in parallel columns ; so thai, 
like twin productions of the same prolific parentage, they may 
become familiar with each others features, and general 
characteristics ; for certainly, at first sight, they will not 
be able to recognize their uear relationship. 



Extract from Mr. McGreevi/s " Testi- 
mony. " October \2th, 1876. 

" 1 was very anxious that the thing," 
(to wit, the Government Contract), 
•' should be put through as soon as 
possible ; and that there should be no 
delays. 1 signed an Agreement during 
these interviews with the Plaintiff, upon 
which this actionis based, in order that 
there should be no delays, as before 
stated, knowing that the Plaintiff had 
the means in his power of keeping it 
back; which J would not have done 
under any other circumstances. It was 
not signed for services rendered, and 
only for the reason above mentioned. " 



Extract from Mr. McGreevi/s " Ans- 
wer. " February isth, 187/. 

" And the Defendant avers, that the 
said notes, and the said moneys were 
given ; and the letter by the Defendant 
signed, dated Quebec, li<th August, 
1875, upon which the Plaintiffs action 
is founded, and declared upon in his 
declaration, were solicited by the said 
P.ainliff, and written and consented by 
the Defendant, and by the Plaintiff 
received as a bribe ; and with the cor- 
rupt intention that he, the Plaintiff, 
should fail in his duty, as such officer 
of the North Shore Railway Company 
in its relations with the said Defen- 
dant ; and not exact from the said 
Defendant, a strict and faithful per- 
formance of the said Defendant's Con- 
tract as Contractor for the Road. " 



It will be remembered that this Answer was prepared 
by the Defendant's Attorney's, and probably at the De- 
fendant's dictation, the day after it was known that the 



MCGREEVY, Versus MCGREEVY. 19 

Court had decided, with reference to the first case : " that 
the Defendant hath failed to prove the Allegations of his plea : " 
and also " that the Plaintiff hath proved the material allega- 
tions of his Declaration;''' and, finally, that: " The Court 
doth adjudge and condemn the Defendant, for the considera- 
tions aforesaid, to pay to the Plaintiff the sum of Five thousand 
dollars, with interest and costs!' 

It would certainly, and very naturally be expected, that 
a Defence in an exactly similar case ; and prepared under 
the immediate negative inspirations of such a decision 
from the Court, would contain some points and allegations 
upon which to base a last, and most probably a "forlorn 
Hope" that were not contained in the Defence to the first 
action under the same Agreement; but I must confess, 
that, even with my somewhat intimate knowledge of the 
Defendant's real character; which knowledge has been 
acquired during the past few years of the most painful 
and humiliating business intercourse and relations with 
him, I was not quite prepared to witness such a degree of 
moral obliquity and turpitude, as are exhibited in the above 
" Evidence " and " Defence " in this case. 

As to how far these remarks will apply to Attorneys, or 
Counsel lers at Law, who have deliberately affixed their 
signatures to a Defence of the above nature, in the face of 
the sworn statements of their own client, I will leave for 
others than myself to judge. 

The important facts, that for several months previous 
to the date of the Agreement in question, I had ceased to 
exercise any control whatever, over the character of the 
work embraced in the Defendant's Contract with the 
Railway Company ; and also, that, at the date of the 



20 FURTHER STATEMENT OF FACTS. 

Agreement, the "Railway Company had practically ceased to 
exist, by reason of having declared its inability to progress 
with the work under existing arrangements ; and having 
at the same time, invested the Provincial Government 
with full power to make such Arrangements with the 
Contractor, as it might think proper, in the public in- 
terest ; all of which facts, although fully proven, and even 
admitted by the Defendant, upon the first trial, seem to have 
been entirely forgotten, or intentionally ignored, by the 
Defendant and his Attorneys, in the preparation of their 
Defence in the second suit, under the same Agreement. 

It seems also, to be still more extraordinary, that the Chief 
point of Defence set up in the present suit, should have been 
entirely forgotten, or intentionally ignored by the Defen- 
dant and his learned Attorneys and Counsel, in the Answer 
to, and trial of the first suit under the same Agreement. 

The further important fact seems also to. have been 
entirely overlooked by the Defence, in both cases, to wit : 
that in aiding the Defendant in his negotiations with the 
G-overnment, the Plaintiff was depriving himself of his 
salary as Consulting Engineer of the Road, during its 
entire construction ; an equivalent for which, and nothing 
more, wa provided for in the Agreement of August 18th 
1875. 



CONCLUDING REMARKS 



My " Explanatory " to the " Statement of Facts, " herein- 
before referred to, closed with the following remarks : 

" I will venture to add however, that if the facts as herein 
set forth, afford any indication of the nature of the prin- 
ciples which have heretofore governed, and still govern the 
Honorable Thomas McG-reevy, in his business transac- 
tions ; and in his ideas of honesty and fair dealing with 
his fellow men, it is a mystery to me, how he has reached 
the present exalted social, political, and financial positions 
which he claims to enjoy. 

" Feeling anxious, if possible, to obtain a solution of this 
problem, I shall watch, with more than ordinary solicitude, 
the result of the application of the same principles, as 
already initiated, in the carrying out of the great and 
important Undertaking, with which he has been entrusted 
by the Provincial Government. " 

I will now close the present " Further Statement of Facts" 
with only the additional remarks ; that I shall continue to 
watch with equal, if not greater solicitude, the result of the 
application of the same, or if possible, more corrupt prin- 
ciples, as already not only initiated, but fully developed 
by Mr. McG-reevy, in his repudiation of his solemn Agree- 
ment of August 18th, 1875. 



22 FURTHER STATENENT OF FACTS. 

I have always had an abiding, and I humbly trust, a 
religious faith, in the doctrine of retributive justice ; and also, 
in the doctrine of future, and, to a certain extent, of present 
rewards and punishments. But I will frankly confess, that 
if the course taken in this matter, by the Honorable Thomas 
McGTreevy, M. P., and Government Contractor for the North 
Shore Railway, shall prove successful on his part ; and 
at the same time destructive, as it must consequently prove* 
to my own private character and professional reputation ; 
my faith will be very considerably shaken, as to the theory 
of present rewards and punishments ; but it will, at the 
same time, be very much strengthened, as to" the nature 
and extent of the rewards and punishments, that are quite 
sure to be meted out, in that future world, to which we are. 
all so rapidly, and so certainly hastening. 

If Mr. McG-reevy chooses to continue to occupy the 
position of a prominent party to a gigantic scheme of bribery 
and corruption, such as his Attorneys aver, and solemnly 
declare, in his Answer, that he is able to prove before the 
Court, at any time when called upon to do so, I shall 
certainly not object ; but he must excuse me from volun- 
tarily accompanying him down to these depths of infamy 
and disgrace. 

Feeling, as I sincerely do, an abiding consciousness of 
having, in the most perfect honor and good faith, performed 
all, and even more than I undertook, or than Mr. McG-reevy 
could have expected me to do, under the Agreement in 
question; and that in doing this, I not only benefitted 
him to the extent of several hundred thousand dollars ; 
but also carried out, to the fullest extent, the expressed 
wishes and desires of the Railway Company, whose servant 



CONCLUDING EEMARKS .23 

and salaried officer I was ; while/at the same time, I acted 
in the most perfect good faith towards the member of the 
Provincial Government, who was conducting the nego- 
tiations with Mr. McGreevy, I shall most certainly continue 
my efforts to obtain such justice from him. as the laws of 
the land will accord to me ; not only for the services which 
I rendered to him under the Agreement in question ; but 
also for the great damage which he has inflicted upon me, 
by reason of his fraudulent representations, in connection 
therewith. 

Even during the short space of time that has already 
intervened, since these atrocious calumnies have been 
spread upon the public records of the Court, they have 
been caught up by the news-paper Press, and spread 
through the entire country like wild- fire ; accompanied by 
comments and remarks, that are calculated to, and must 
necessarily inflict an irreparable injury upon my personal 
character, and professional reputation ; which are now< 
and always have been my only working capital ; and 
without which, pure and usullied, no Civil Engineer can 
hope for success in his Profession. 

By immediately supplying the Press, and the leading 
business men of this Country, the United States, and 
Europe, with a well authenticated " Statement of Facts " in 
the case, I may perhaps counteract the evil to some extent ; 
but it never can be fully remedied. 

SILAS SEYMOUR 
General Consulting Engineer. 

Quebec, February 17th 1877. 



SUPPLEMENT. 



LATEST EDITION OF FACTS, 



" 4 few more of the same sort left." 

Old Razor-Strop-Man. 



Inasmuch as events have occurred, since the foregoing 
" Statement " has been put in type, which may have an 
important bearing upon the matter. I have felt it my duty 
to stop the Press, for the purpose of placing before the 
Public, the latest " Facts " in this most remarkable Case. 

After I had respecfully declined to accede to any terms 
of settlement with the Honorable Thomas McG-reevy, that 
did not recognize his full obligation to carry out his 
Agreement of August 18th 1875 ; and also a full and un- 
qualified retraction by him, of all his slanderous allega- 
tions against me, in connection therewith : 

And after the Defendant had been served with a notice 
to appear in Court, on Monday morning, February 19th, 
1877, and answer certain interrogatories, [Fails et Articles) 
with which he was furnished, in relation to the truthful- 
ness or falsi lj/ of the allegations contained in the Plaintiff's 



2 SUPPLEMENT. 

Declaration, and the Defendant's Answer, in the Case now 
pending : 

And after it had become generally known, that 1 was 
preparing the foregoing " Further Statement of Facts 1 ', for 
the purpose of placing all these matters in their true light 
before the Public; and thus counteracting, as far as possi- 
ble, the injury which I was sustaining from the general 
circulation of his libellous calumnies, against my private 
character and professional reputation : 

And after I had sent to the Editor of the Quebec " Morn- 
ing Chronicle, " the following communication upon the 
subject : 

" Sir, — I have observed in a recent issue of the Chronicle ; 
and also in the Montreal and other papers, allusions to 
the matters in difference between Mr. McGrreevy and 
myself, respecting the North Shore Eailway ; all of which 
are calculated to injure my private character and profes- 
sional reputation. 

" May I ask that the Chronicle, and other papers 
throughout the country, w T ill kindly refrain from any fur- 
ther remarks of this nature, until I can furnish to the Press, 
and the Public generally, a w T e!l authenticated " Statement 
of Facts" in the case; which I hope to have ready for 
general circulation, within a day or two. 

Yery respectfully, 

S. Seymour, 
General Consulting Engineer. " 

Quebec, Feb. 17, 1877. 

After the occurrence of the above mentioned events, it 
appears to have been suddenly discovered by the Honorable 
Thomas McGreevv, M. P., and Government Contractor for 



LATEST EDITION OF FACTS. 3 

the North Shore Railway, that his Parliamentary duties 
imperatively required his immediate presence in Ottawa, 
the Capital of the Dominion. 

The Local column of the Quebec " Morning Chronicle" of 
Monday, Feb. 19th, 1877, therefore contained the following 
important item of information : 

" Personal. — Hon. Mr. McGreevy, M. P. for Quebec 
"West, was to have left for Ottawa on Saturday evening, to 
attend to his sessional duties." 

The Editorial column of the same paper, was also headed 
with the following double-leaded, and startling announce- 
ment : 

** We are authorized by Mr. McGrreevy to state, that the 
plea fyled in the Court House, and alluded to in the Press, 
was not authorized by him, and was done without his 
knowledge or consent." 

When the Case of Seymour versus McGreevy, was called 
in the Superior Court, at half past ten, on the same 
eventful Monday morning, Mr. F. W. Andrews, Q. C, of the 
Law Firm of Andrews, Caron and Andrews, a fine venerable 
looking G-entleman, who I am assured, wrote the " Plea 
fyled in the Court" to which allusion is made in the above 
News-Paper Editorial ; and whom, I know, heard, and paid 
the closest attention to every word of his Honorable Client's 
testimony, as given at Enquete on the 12th Oct., 1876, in 
the first suit, and under the same Agreement; which 
testimony, as has already been shown, belies £the entire 
latter portion of the Plea : This G-entleman, after having, 
as I am credibly informed, consulted fully with his asso- 
ciate Counsel in the Case, arose in response to the above 
call, and applied to the Honorable Court for a postponement 



4 SUPPLEMENT. 

of the Case, upon the ground that the rule which had 
been personally served upon Mr. McG-reevy, three days 
previously, ordering him to answer certain interrogatories 
therein mentioned, had issued prematurely ; by reason of 
which, he had taken the responsibility of advising his 
Honorable Client, that it was his privilege and duty to obey 
the call of his Country, instead of ihe Summons of the Court; 
and that the Expected Witness had consequently left for 
Ottawa. 

After a most scathing and earnest argument and pro- 
test, by Mr. E. Alleyn, Q. C, of Messrs. Alleyn and Chau- 
veau, my own Attorneys, the Honorable Court thought 
proper to postpone a further hearing in the Case, until 
March 9th, 1877. 

If it had been the desire or intention, of the Defendant 
to make any responsible denial, or explanation of the 
calumnious Plea in question, with a view of shielding 
himself from the responsibilities connected therewith ; 
and at the same time, protecting me, as far as it was then 
possible, from further injury therefrom ; it is quite evident 
that he had been furnished, by my oivn Attorney, with a 
most favorable opportunity of doing so, by appearing in 
Court, and answering the interrogatories which had pre- 
viously been propounded to him. 

Instead of doing this, however, it will be seen, that by 
the deliberate and concurrent action of the Honorable 
Defendant, and his learned and venerable Attorney, and 
Counsel, I am compelled to rest, so far as the records of 
the Court are concerned, for several weeks to come, under 
the public charge and allegation of having been a party, 



LATEST EDITION OF FACTS. 5 

with the Honorable Thomas McGrreevy, M. P., and Govern- 
ment Contractor for the North Shore Kail way, to a vile con- 
spiracy to defraud my employers ; and also of having- corruptly 
accepted a bribe, for the same dishonorable purpose. 

Eeferring a moment, however, to the most extraordinary, 
and totally irresponsible announcement contained in the 
Editorial column of the " Morning Chronicle^ above re- 
ferred to, it would appear, that the celebrated Plea, or 
Answer in question, has been placed in a most anomalous* 
if not embarrassing position. 

If any reliance is to be placed in the Newspaper Editorial^ 
above referred to, this Plea has been driven from the 
protecting roof of its reputed Father, or God-Father, which- 
ever he may be ; and the poor Bantling, or Orphan, is now 
wandering about, like " Japhet in search of a Father " ; or 
perhaps, more legally speaking, like a Defence in search of a 
Defendant, in the vain endeavor to induce some kind 
hearted and charitable individual, to afford if shelter and 
protection. 

Feeling as I do, a great interest in this poor and 
forsaken Outcast ; notwithstanding it has been the cause 
of the deepest injury to me, I will, if such shall prove to 
be the case, be most thankful to any responsible party 
who will either acknowledge its paternity ; or furnish 
such reliable information as will lead to their early dis- 
covery. 

So far as I am personally concerned, however, the 
Honorable Defendant, and all parties in interest, may rest 
assured, that no News-paper Editorial ; nor any legal quibble, 
which either he, or his Attorney, and Counsel may pro- 



6 SUPPLEMENT. 

mulgate, or resort to, will divert me from my settled purpose 
to pursue this whole matter to its legitimate conclusions ; 
under the full conviction that : 

" Thrice armed is he whose cause is just." 

SILAS SEYMOUR. 
Quebec, February 20th, 1877.